The importance of transfer pricing as a reputational issue means it is critical that taxpayers have the right policies to enable them to comply with their obligations on the topic around the world.
Businesses need to understand national rules on related-party transactions, develop the best ways - including having the right technology - to adhere to them and maintain an awareness of how the rules might be changed or added to in the future.
Their knowledge and understanding of national transfer pricing laws and rulings in a given jurisdiction allows tax departments to make the right decisions on subjects, such as the financing of a subsidiary, the location of an R&D project, the suitability of an advance pricing agreement, the correct methodology when documenting a transaction or the approach to take when faced with an audit, as well as monitor tax risk.
Australia, Canada and the UK are three jurisdictions that have proposed amendments or gone ahead with rewrites to their transfer pricing regimes in the last few months. Advance pricing agreements are now possible in Hong Kong and India - though no guidance has been published in that country yet. And concepts such as management fees and location savings are getting wider exposure around the world.
These are important developments that require careful thought and analysis, particularly at a time when transfer pricing rules and regulations are developing rapidly all over the world, judges are getting the opportunity to interpret existing laws, sometimes in unforeseen ways, and tax administration is becoming more and more international, with ideas and tips being passed back and forth by revenue authorities all the time.
The Ask the Authorities panel at September’s Global Transfer Pricing Forum, hosted by International Tax Review and TPWeek, offers executives a unique platform to get answers to their questions about related-party matters.
Officials from three countries will field queries about all aspects of transfer pricing during the 75-minute discussion at 1.30pm on September 25. The agenda covers documentation, legal certainty, advance pricing agreements, joint audits and alternative dispute resolution, though the participation of Michelle Levac, of the Canada Revenue Agency, who chairs the OECD’s Working Party No 6, makes it likely that the multilateral organisation’s most recent projects on intangibles and restructuring will also come up.
The other panellists are Eric Lesprit, the head of the APA team at the French Tax Administration and Peter Steeds, who took over as head of transfer pricing at HM Revenue & Customs in the UK last October.
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